Carl Klein - Page 5




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          verification of reasonable cause for abatement of additions to              
          tax and that respondent would assume that there was none unless             
          such was provided within the next 15 days; (2) that consideration           
          of petitioner’s bankruptcy assertion must be made in the light of           
          the new bankruptcy laws which take “a harder look at future                 
          income than the old law did”.  The settlement officer noted that            
          “You have significant income potential, as you have displayed               
          through past performance, and I do not think that you would avoid           
          paying all the taxes if you file [for bankruptcy]”; and (3) that            
          if petitioner wished to enter into an installment agreement, he             
          should, through his representatives, contact respondent within 15           
          days.                                                                       
               Petitioner responded to the settlement officer’s December              
          22, 2005, letter by reiterating his position that respondent had            
          not given adequate consideration to his potential bankruptcy                
          because respondent had not considered that his future earnings              
          were uncertain because petitioner was aging and was at that time            
          practicing law without associates and without a formal office or            
          support staff.  In addition, petitioner contested the settlement            
          officer’s calculation of petitioner’s realizable collection                 
          potential, claiming that increased allowances should have been              
          made for petitioner’s basic living expenses.  Petitioner did not            
          attempt to enter into an installment agreement and did not                  
          respond to the invitation to submit verification of reasonable              







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